New Account Holds Under Reg CC

10/3/2026

The new-account exception is the broadest hold authority in Regulation CC. For the first 30 days of an account's life, most of the availability schedule simply does not apply to ordinary checks, there is no regulatory maximum on how long they can be held, and no per-hold notice is required. That is a lot of latitude, and it exists for a good reason: a bank knows almost nothing about a brand-new depositor, and new accounts are where a large share of check fraud lands.

The latitude is also where banks get into trouble. The exception has a precise definition, a short list of deposits it cannot touch, and a hard limit for certain checks. Apply it to someone who is not a new customer, or keep applying it after day 30, and every hold placed under it becomes a violation. This guide works through the rule in 12 CFR 229.13(a) and its official commentary, from the definition to the system settings that keep it honest.

Dollar figures are the amounts in effect since July 1, 2025. They are adjusted for inflation every five years, with the next scheduled adjustment on July 1, 2030.

What Counts as a New Account

Regulation CC section 229.13(a)(2) gives the test in two sentences:

An account is a new account during the first 30 calendar days after the account is established.
An account is not a new account if each customer on the account has had, within 30 calendar days before the account is established, another account at the depositary bank for at least 30 calendar days.

The commentary adds two clarifications. First, an account is opened when the first deposit is made to it. Second, the existing relationship that disqualifies a customer must be a transaction account relationship, which can include a dormant account, that is at least 30 calendar days old, or an established transaction account the customer held within the 30 days before opening the new one.

Calendar days, not business days

The 30-day period runs in calendar days. Most of Regulation CC counts business days, so this is a place where a teller's instinct from the rest of the hold chart leads them astray. A 30-calendar-day window that starts on the day of the first deposit ends on a fixed date, and the system should know that date.

"Account" means a transaction account

Regulation CC applies to "accounts" as defined in section 229.2(a): transaction accounts such as checking, NOW and share draft accounts. Savings deposits are not accounts for Subpart B purposes. That definition cuts two ways for the new-account exception:

A customer whose only relationship with the bank is a savings account or a certificate of deposit is still a new customer when opening a checking account. The commentary says so directly.
A customer who opens a new savings account is not opening a Regulation CC account at all, so the availability rules, and this exception, do not govern it.

The commentary's examples

The official commentary walks through the common situations, and they make good teller training material:

Situation	New account?
Customer with an established checking account opens a second checking account	No
Customer's account closed and replaced because of stolen checks or a compromised debit card, where the original relationship is at least 30 days old	No
Customer closes an established account and opens a separate account within 30 days	No
Customer with only a savings deposit or other non-transaction deposit opens a checking account	Yes
Authorized signer on a corporate account, with no other relationship, opens a personal account	Yes
Customer with an established joint account opens an individual account	No
Two customers who each have established individual accounts open a joint account	No
Joint account where one owner has no current or recent established account relationship	Yes

The last row catches many banks off guard. The test is whether each customer has the qualifying relationship. One established customer cannot lend that status to a new co-owner, so the joint account is new.

Relying on the customer's word

The bank may rely on the customer's representation that he or she has no established account relationship with the bank and has not had one within the past 30 days. That matters most for institutions whose systems cannot easily look across product lines or legacy platforms. It does not excuse ignoring information the bank already has: if the customer information file shows a three-year-old checking relationship, the account is not new.

Mergers

Regulation CC lets merging banks be treated as separate banks for one year after a merger for most Subpart B purposes, but section 229.19(g) expressly excludes the new-account exception from that treatment. A customer of the acquired bank with an established account is not a new customer of the combined bank merely because the charters merged. If your bank is integrating an acquisition, the bank merger compliance integration checklist is the place to flag this, because the customer file conversion is what makes it work.

What the New-Account Exception Does to Availability

Section 229.13(a)(1) sorts deposits into three groups during the new-account period.

Group 1: Cash and electronic payments keep next-day availability

Cash and electronic payments (wire transfers and ACH credits) remain subject to section 229.10(a) and (b). Cash deposited in person to an employee must be available the next business day. Cash not deposited in person, for example at a proprietary ATM, follows the second-business-day rule in 229.10(a)(2). Electronic payments are available the business day after the bank receives them.

That means a new customer's direct-deposited paycheck cannot be held under the new-account exception. Neither can the cash he or she hands the teller to fund the account.

Group 2: Certain checks keep next-day availability up to $6,725

These checks keep their next-day (or second-day) treatment for the first $6,725 deposited on any one banking day:

S. Treasury checks
S. Postal Service money orders
Checks drawn on a Federal Reserve Bank or Federal Home Loan Bank
State and local government checks
Cashier's, certified, and teller's checks
Traveler's checks, which are added to this group for the new-account exception only

The usual conditions still apply. Most of these must be deposited into an account held by a payee, and most must be deposited in person to an employee to get next-day treatment; otherwise they are available on the second business day. Treasury checks deposited into a payee's account get next-day availability even if not deposited in person.

The amount over $6,725 must be available no later than the ninth business day after the banking day of deposit.

The commentary adds a detail that systems often miss: for all new accounts, traveler's checks must be included in the $6,725 aggregation of these next-day checks, even if the bank does not actually invoke the new-account exception.

Group 3: Everything else has no regulatory maximum

During the new-account period, the regulation does not apply section 229.10(c)(1)(vi) (on-us checks), section 229.10(c)(1)(vii) (the $275 next-day minimum), or section 229.12 (the local and nonlocal schedule). The commentary is explicit that the regulation provides no maximum time frame for these deposits during the new-account period, and the "reasonable period" limit in 229.13(h) does not apply to the new-account exception.

In practice, a personal check deposited into a new account can be held beyond the usual seventh-business-day ceiling that applies to other exception holds. That does not mean an unlimited hold is wise. The bank's disclosed policy must state how long new-account holds generally run, and holding funds far longer than the disclosure says, or far longer than needed to learn whether a check will be returned, creates complaint and UDAAP exposure even where Regulation CC is silent.

A worked example

A new customer opens a checking account on a Monday and, in person at the teller line, deposits:

$500 in cash
An $8,000 cashier's check payable to her
A $1,200 personal check payable to her

Under the new-account rules:

The $500 cash must be available Tuesday (next business day).
$6,725 of the cashier's check must be available Tuesday, because it was deposited in person into the payee's account.
The remaining $1,275 of the cashier's check must be available no later than the ninth business day after Monday.
The $1,200 personal check has no Regulation CC maximum during the new-account period; the bank applies the hold stated in its availability disclosure.
The $275 next-day minimum does not apply.

If the same cashier's check were deposited through the bank's ATM instead, the first $6,725 would be available on the second business day rather than the first.

Notice and Disclosure

The new-account exception is the one exception that does not require the per-hold notice in section 229.13(g). The notice rule covers the large-deposit, redeposited-check, repeated-overdraft and reasonable-cause exceptions, and separate notice rules cover emergencies.

Disclosure still matters, for two reasons:

The initial disclosure must describe it. Section 229.16(b)(3) requires the specific availability policy disclosure to describe any exception the bank may invoke, including the time following a deposit when funds generally will be available. Section 229.17 requires that disclosure before the account is opened, which in practice means before the bank accepts the opening deposit. Appendix C includes a model clause titled "Special Rules for New Accounts." Be careful copying it: the model text in the regulation still prints older dollar figures (it refers to the first $5,000 of a day's deposits, for example), so a bank must substitute the current $6,725 amount and confirm every other figure against the current rule.
Other exceptions still need notices. If the bank holds a new customer's check because of a stop-payment notice, a stale date, or another specific fact, it is invoking the reasonable-cause exception, not the new-account exception, and the full notice and recordkeeping rules apply.

Many banks also choose to hand a courtesy hold notice to new customers at the counter. It is not required for the new-account exception, but it heads off the most common complaint, which is a customer who did not understand why the first deposit was not spendable.

How the Exception Interacts With Other Holds

Large deposits. For the next-day check types, the new-account rule already limits next-day treatment to the first $6,725, and the excess runs to the ninth business day. Ordinary checks in a new account are not on a schedule at all, so the large-deposit exception adds little during the first 30 days.

After day 30. On day 31, the account is no longer new. Every Regulation CC rule applies normally to deposits made from that point, including the $275 next-day minimum, the second-business-day schedule for local checks, and the notice requirements for any exception hold.

Fraud signals. New accounts are a frequent channel for counterfeit cashier's checks and altered items. The new-account exception does not let a bank ignore the $6,725 next-day requirement for a cashier's check because it looks suspicious; if there are specific facts, the bank can invoke the reasonable-cause exception with notice. Our guide to check fraud detection covers the indicators that can support that judgment, and the digital account opening post covers the onboarding controls that come before it.

Configuring Systems So the Exception Ends on Time

The new-account exception is mostly a systems problem. Four settings deserve a test every year:

The start date. The period should start with the first deposit, not the date the account record was created or the date the signature card was signed, unless those are the same day.
The end date. The flag must clear automatically after 30 calendar days. A manual review queue is not a control.
The relationship check. The system should look for any qualifying transaction account held by each owner, including dormant accounts and accounts closed within the past 30 days. Savings-only and loan-only relationships should not count.
The $6,725 parameter. Confirm it changed from $5,525 on July 1, 2025, and that traveler's checks are included in the aggregation.

A short test script, a handful of sample accounts with known opening dates and ownership, run through the core system after any upgrade, will find most of these problems before an examiner does.

Training the Front Line

New-accounts representatives and tellers are the people who explain this rule to customers, and the people whose overrides can undo a correct system setting. They need to know the definition well enough to answer "I've banked here for years" correctly, the next-day categories well enough to release a cashier's check on time, and the disclosure well enough to describe it. Our Expedited Funds Availability (Reg CC) course is dedicated to this regulation. For the onboarding side, the Deposit Accounts and Services course and our broader deposit compliance training catalog are related options, and the bank teller training guide shows where funds availability fits in a teller's first months.

Frequently Asked Questions

What is a new account under Reg CC?

Under 12 CFR 229.13(a)(2), an account is a new account during the first 30 calendar days after it is established, and the commentary treats an account as opened when the first deposit is made. An account is not new if each customer on it has had another transaction account at the same bank for at least 30 calendar days, either currently or within the 30 days before the new account was opened. Savings-only or loan-only relationships do not count, so a savings customer opening checking is a new customer.

How long is the new account period under Reg CC?

Thirty calendar days, counted from the day the account is established, which the commentary treats as the day of the first deposit. Unlike most of Regulation CC, the period is measured in calendar days rather than business days. On the 31st day the account is no longer new, and every deposit made from then on receives normal Regulation CC availability, including the $275 next-day minimum and the second-business-day schedule for local checks, unless another exception applies with proper notice.

Which deposits get next-day availability in a new account?

Cash and electronic payments, such as wire transfers and ACH credits, keep their normal next-day availability. Treasury checks, Postal money orders, Federal Reserve and Federal Home Loan Bank checks, state and local government checks, and cashier's, certified, teller's, and traveler's checks keep next-day (or second-day) treatment for the first $6,725 deposited on a banking day, provided the usual payee and in-person conditions are met. The excess over $6,725 must be available by the ninth business day.

How long can a bank hold a personal check in a new account?

Regulation CC sets no maximum. During the new-account period, the local-check schedule, the on-us rule, and the $275 next-day minimum do not apply, and the reasonable-period limit for other exceptions does not reach the new-account exception. The bank must still disclose its new-account policy before opening the account, including when funds will generally be available, and should follow that disclosure. Holding funds far beyond the disclosed period invites complaints and possible UDAAP scrutiny.

Does a bank have to give notice of a new account hold?

Not per hold. The exception notice requirement in 229.13(g) applies to the large-deposit, redeposited-check, repeated-overdraft and reasonable-cause exceptions, not to the new-account exception. The bank must, however, describe the new-account rules in its specific availability policy disclosure, which must be provided before the account is opened. If the bank holds a new customer's check because of specific facts about that item, it is using the reasonable-cause exception and must give that exception's notice.

Is a joint account a new account if one owner already banks with us?

It can be. The test asks whether each customer on the account has a qualifying established transaction account relationship. If two existing customers open a joint account, it is not new. If one owner has an established checking account and the other has no current or recent transaction account with the bank, the joint account is a new account, according to the official commentary. One owner's history does not carry over to a new co-owner.

Get the First 30 Days Right

The new-account exception is generous, but only inside its boundaries: the right customers, the right deposits, the right 30 days, and a disclosure that tells the customer what to expect. Our Expedited Funds Availability (Reg CC) course gives tellers and new-accounts staff a dedicated grounding in the regulation they apply to every opening deposit.